Patient safety and licensure standards must come first
My name is Emilie Ellis, and I’m a licensed and registered dental hygienist.
I’ve been practicing for almost 12 years and have been an educator for almost 10.
I am writing in strong opposition to Senate Bills 282 and 178, and House Bills 1036 and 970. These bills ask dental professionals to perform duties without proper education and training.
A key concern is on-the-job training for preventive dental assistants. This model is a significant step backward for oral healthcare in Virginia because it does not prioritize patient safety or the educational and clinical competencies required for safe, evidence-based dental hygiene practice.
Scaling requires advanced instrumentation skills, assessment, and critical clinical judgment. These competencies are taught in Commission on Dental Accreditation (CODA) accredited dental hygiene programs and performed by licensed dental hygienists.
Allowing unlicensed personnel to perform these procedures jeopardizes patient safety and undermines the integrity of the dental hygiene profession.
Beyond clinical concerns, these bills introduce insurance, billing, and legal risk. Because preventive dental assistants cannot perform a complete prophylaxis, clinics may be forced to use alternative billing codes with different justifications and lower reimbursement. That creates pressure that can lead to improper coding, misrepresentation of services, or billing for incomplete care.
Those scenarios expose practices to insurance disputes, audits, and potential allegations of fraud. When unlicensed personnel perform procedures outside their legal scope, claims submitted to insurers (including Medicaid) may be considered inaccurate or misleading.
Regarding the bills that would allow internationally trained dentists to obtain licensure as dental hygienists in Virginia without CODA-accredited hygiene education and required clinical training: these proposals do not solve the workforce gap. They do not create new hygienists and may drive currently licensed hygienists out of the field.
This legislation represents a significant step backward for patient safety, professional standards, and evidence-based oral healthcare in the Commonwealth.
Dental hygiene is not a subset of dentistry. It is a distinct, prevention-focused profession with its own body of knowledge, competencies, and clinical training requirements.
Core responsibilities of licensed dental hygienists—including comprehensive periodontal assessment, scaling and root debridement, preventive therapy, patient education, and risk-based clinical judgment—are not equivalently taught or emphasized in dental school curricula, whether domestic or international.
Dental education primarily focuses on diagnosis and restorative treatment after disease occurs, while dental hygiene education is built around prevention, early intervention, and long-term disease management.
These competencies are developed through extensive supervised clinical education in CODA-accredited entry-level hygiene programs and reinforced through rigorous clinical courses and labs designed to assess safe, competent hygiene practice.
Allowing individuals, regardless of prior dental training, to bypass these requirements lowers standards of care, places patients at risk, and undermines the integrity of the dental hygiene license.
It also sets a dangerous precedent: professional licensure standards could be relaxed based on workforce convenience rather than evidence or outcomes.
Proponents argue these bills expand access to care, but there is no evidence that weakening licensure standards improves access or outcomes. The people with the greatest need are not the people most likely to benefit.
These bills are more likely to affect suburban and urban settings, and do not solve access issues in communities with too few supervising dentists.
I urge you to vote no on these bills. We, as dental professionals, do not support them.
Thank you for your time.
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